The Facebook, Inc. v. Connectu, Inc et al

Filing 221

Declaration of Scott R. Mosko in Support of Defendants Winston Williams and Pacific Northwest Software, Inc.'s Opposition to Plaintiffs' Motion to Compel Supplemental Responses to Interrogatory Nos. 3 and 4 filed by Pacific Northwest Software, Inc., Winston Williams. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4-A# 5 Exhibit 4-B# 6 Exhibit 5# 7 Exhibit 6# 8 Exhibit 7# 9 Exhibit 8)(Mosko, Scott) (Filed on 11/7/2007) Text modified on 11/8/2007 (bw, COURT STAFF).

The Facebook, Inc. v. Connectu, LLC et al

Doc. 221

Case 5:07-cv-01389-RS

Document 221

Filed 11/07/2007

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Scott R. Mosko (State Bar No. 106070) FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, LL.P. Stanford Research Park 3300 Hillview Avenue Palo Alto, California 94304 Telephone: [phone] Facsimile: [phone] Attorney for Defendants Winston Williams and Pacific Northwest Software, Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION FACEBOOK, INC., and MARK ZUCKERBERG Plaintiffs,
V.

CASE NO. C 07-01389 RS DECLARATION OF SCOTT R. MOSKO IN SUPPORT OF DEFENDANTS WINSTON WILLIAMS AND PACIFIC NORTHWEST SOFTWARE, INC.'S OPPOSITION TO PLAINTIFFS' MOTION TO COMPEL SUPPLEMENTAL RESPONSES TO INTERROGATORY NOS. 3 AND 4 Date: Time: Dept.: Mag. Judge: November 28, 2007 9:30 a.m. 4 Hon. Richard Seeborg

CONNECTU LLC, (now known as CONNECTU, INC.), CAMERON WINKLEVOSS, TYLER WINKLEVOSS, DIVYA NARENDRA, PACIFIC NORTHWEST SOFTWARE, INC., WINSTON WILLIAMS, WAYNE CHANG, DAVID GUCWA, and DOES 1-25, Defendants.

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1 Doe. No. 473371

MOSKO DECLARATION ISO OPPOSITION TO PLAINTIFFS' MOTION TO COMPEL Case No. 07 CV 01389 (RS)

Dockets.Justia.com

Case 5:07-cv-01389-RS

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DECLARATION OF SCOTT R. MOSKO

I, Scott R. Mosko declare, 1. 1 am an attorney duly licensed to practice law in the state of California and before the

Northern District of California. I am a member of Finnegan, Henderson, Farabow, Garrett & Dunner, LLP, attorneys of record for Defendants Winston Williams and Pacific Northwest Software, Inc. The matters referred to in this declaration are based on my personal knowledge and if called as a witness I could, and would, testify competently to those matters. 2. Attached hereto as Exhibit I is a true and correct copy of a November 5, 2007 letter

from myself to Theresa Sutton, counsel for plaintiffs. 3. Attached hereto as Exhibit 2 is a true and correct copy of excerpts from the transcript

of the January 29, 2007 deposition of John Taves taken in the Superior Court for the County of Santa Clara action, Case No. 1:05-CV-047381. 4. Williams. 5. Attached hereto as Exhibit 4-A is a true and correct copy of Defendant Pacific Attached hereto as Exhibit 3 is a true and correct copy of a Declaration of Winston

Northwest Software's Response to First Set of Interrogatories. 6. Attached hereto as Exhibit 4-B is a true and correct copy of Defendant Winston

Williams' Response to First Set of Interrogatories. 7. Attached hereto as Exhibit 5 is a true and correct copy of excerpts from the transcript

of the June 19, 2007 deposition of Winston Williams. 8. Attached hereto as Exhibit 6 is a true and correct copy of a September 10, 2007

through October 17, 2007 e-mail string containing communications between plaintiffs' counsel and myself. 9. Attached hereto as Exhibit 7 is a true and correct copy of a September 10, 2007

through October 4, 2007 e-mail string containing communications between plaintiffs' counsel and myself. 10. Attached hereto as Exhibit 8 is a true and correct copy of a October 31, 2007 letter

from myself to Theresa Sutton, counsel for plaintiffs.
I Doc. No. 473371 MOSKO DECLARATION ISO OPPOSITION TO PLAINTIFFS' MOTION TO COMPEL Case No.07 CV 01389 (RS)

Case 5:07-cv-01389-RS

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I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct, and that this declaration was executed on the 7th day of November, 2007, in Palo Alto, California.

Is! Scott R. Mosko

2 Doe. No. 473371

MOSKO DECLARATION ISO OPPOSITION TO PLAINTIFFS' MOTION TO COMPEL Case No.07 CV 01389 (RS)